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3 December 1990 Administrative Letter 903016 F- Private Corporation Status under Canada-Germany Income Tax Convention Unedited CRA Tags n/a 19(1) 903016   M.P. ...

1 March 1990 Income Tax Severed Letter ACC9218- Canada-USSR Income Tax Convention Unedited CRA Tags Canada-U.S.S.R. ...

7 December 1990 Income Tax Severed Letter- Private Corporation Status under Canada-Germany Income Tax Convention Unedited CRA Tags Canada–Germany Income Tax Agreement Dear Sir: Re: Article 13 of the Canada-Germany Income Tax Agreement (1981) (the “Agreement”) We are writing in reply to your letter dated October 18, 1990 wherein you brought to our attention the fact that the assumption made in our letter dated August 14, 1990 that the West-German “Gesellschaft des buergerlichen Rechts” (“GbR”) is a private corporation is not correct. ...

2001 Ruling 2000-0056883 F- MODIFICATION CONVENTION D'ACHAT D'ACTIONS Unedited CRA Tags 110(1)(d) 7(3)b) 7(1)b) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Est-ce que l'alinéa 7(1)b) s'applique dans le cas où un employé a le droit de choisir une somme en espèces plutôt que des actions en vertu d'une convention d'achat d'actions? ... La convention d'achat d'actions prévoit que des modifications peuvent être effectuées (E9632153,E9618951, E990140, E9818203). 2. et 3. ...

22 October 1990 Internal T.I. 901787 F- Determination of Residence under Canada-Germany Income Tax Convention Unedited CRA Tags n/a 24(1) 901787   L.A. ...

Income Tax Convention Unedited CRA Tags 126(1), 20(12), 20(11) 24(1) 902469   R.S. ...

Income Tax Convention Unedited CRA Tags 20(11), 20(12), 126 Dear Sirs: This is in answer to your letter of September 6, 1990 concerning section 126 of the Income Tax Act (the Act) with respect to a Canadian resident individual who owns shares of a U.S. corporation which corporation elects to be taxed as a subchapter S corporation. ...

Tax Convention Unedited CRA Tags Article IV(7)(b) Principal Issues: Whether Article IV(7)(b) of the Treaty applies to fees paid by a Canadian unlimited liability corporation ("ULC") to a U.S. limited partnership Position: No Reasons: The treatment of the fees under the income tax laws of the U.S. is the same as it would be if the ULC were not fiscally transparent XXXXXXXXXX 2009-034590 XXXXXXXXXX, 2009 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling XXXXXXXXXX XXXXXXXXXX (the "taxpayers") This is in response to your XXXXXXXXXX request for an advance income tax ruling on behalf of the above taxpayers. ... X" means XXXXXXXXXX; (i) "Partnership A" means XXXXXXXXXX.; (j) "Partnership B" means XXXXXXXXXX.; (k) "Province" means XXXXXXXXXX; (l) "qualifying person" has the meaning assigned by Article XXIX-A of the Treaty; (m) "related persons" has the meaning assigned by subsection 251(2) of the Act; (n) "S Corp" means XXXXXXXXXX.; (o) "taxable Canadian corporation" has the meaning assigned by subsection 89(1) of the Act; (p) "taxation year" has the meaning assigned by subsection 249(1) of the Act; (q) "Treaty" means the Convention Between Canada and the United States of America With Respect to Taxes on Income and Capital Signed on September 26, 1980 as Amended by the Protocols Signed on June 14, 1983, March 28, 1984, March 17, 1995, July 29, 1997 and September 21, 2007; and (r) "United States" means the United States of America. ...

2010 Ruling 2009-0349141R3- Canada-United States Tax Convention Unedited CRA Tags Article XI and XXIX A(3) of the Canada-United States Tax Convention (1980); Subsection 18(6) of the Income Tax Act Principal Issues: 1) Whether interest arising in Canada and beneficially owned by a resident of the United States is, pursuant to Article XXIX A(3) and Article XI of the Convention, only taxable in the United States; 2) Whether subsection 18(6) applies to certain loans between related Canadian corporations Position: 1) Yes; 2) No Reasons: 1) The interest is income derived in connection with an active trade or business in the United States that is substantial in relation to the activity in Canada giving rise to the income; 2) Subsection 18(4) is not frustrated or circumvented XXXXXXXXXX 2009-034914 XXXXXXXXXX, 2010 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling XXXXXXXXXX (collectively referred to as the "taxpayers") We are writing in response to your request dated XXXXXXXXXX for an advance income tax ruling on behalf of the above-noted taxpayers. ... In this letter, the following terms have the meanings specified below: "Act" means the Income Tax Act, R.S.C. 1985 c.1 (5th Supp.), as amended; "Canco" means XXXXXXXXXX, a corporation incorporated under the Canada Business Corporations Act; "Canadian Finco" means XXXXXXXXXX, a corporation incorporated under the Canada Business Corporations Act; "Canco Group" means Canco, Canadian Finco, Canadian Salesco and Canadian Treasury; "Canadian Salesco" means XXXXXXXXXX, a wholly-owned subsidiary of US Holdco; "Canadian Treasury" means XXXXXXXXXX, a corporation incorporated under the Canada Business Corporation Act; "CRA" means the Canada Revenue Agency; "Fifth Protocol" means the Fifth Protocol to the Canada-United States Tax Convention (1980); "Foreign Finco" means XXXXXXXXXX, a XXXXXXXXXX company and a wholly-owned subsidiary of Foreign Parent; "Foreign Holdco" means XXXXXXXXXX, a XXXXXXXXXX company and a wholly-owned subsidiary of Foreign Parent; "Foreign Parent" means XXXXXXXXXX, a XXXXXXXXXX public company; "Foreign Treasury" means XXXXXXXXXX, a XXXXXXXXXX company and a wholly-owned subsidiary of Foreign Parent; "FP Group" has the meaning described in paragraph 1 of this letter; "GPCo" means XXXXXXXXXX, a wholly-owned subsidiary of US Holdco; "non-resident" has the meaning assigned by subsection 248(1) of the Act; "Primary Loans" means Primary Loan 1, Primary Loan 2 and Primary Loan 3, as described in paragraph 33 of this letter; "related" has the meaning assigned in subsection 251(2) of the Act; "Secondary Loans" means the Secondary Loans 1, Secondary Loan 2 and Secondary Loans 3, as described in paragraph 33 of this letter; "taxable Canadian corporation" has the meaning assigned by subsection 89(1) of the Act; "Treaty" means the Canada-United States Tax Convention (1980); "US Group" means US Holdco and any of the corporations that are related to US Holdco and that carry on an active trade or business in the United States; "US Holdco" means XXXXXXXXXX, a wholly owned subsidiary of Foreign Parent; and "US Treasury LP" means XXXXXXXXXX, a limited partnership, as described in paragraphs 18 and 19 of this letter. ...

2012 Ruling 2011-0416821R3- Article XII of Canada-US Tax Convention Unedited CRA Tags 212(1)(d); Article XII- Canada-US Treaty Principal Issues: Whether certain payments from a Canadian payor to an arm's length US corporation are in respect of a franchise Position: No Reasons: This was a factual determination XXXXXXXXXX 2011-041682 XXXXXXXXXX XXXXXXXXXX, 2012 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling XXXXXXXXXX This is in response to your XXXXXXXXXX request for an advance income tax ruling on behalf of the above named taxpayers. ... Definitions In this letter, the following terms have the meaning specified: (a) "Act" means the Income Tax Act, R.S.C. 1985, c.1 (5th Supplement) as amended to the date of this advance income tax ruling; (b) "Agreement" means the License and Distribution agreement to be entered into by Pubco, Parent and Canco; (c) "Canco" means XXXXXXXXXX; (d) "CRA" means the Canada Revenue Agency; (e) "Existing Product" means the XXXXXXXXXX product; (f) "Foreign Country" means the United States of America; (g) "Foreign Exchange" means the XXXXXXXXXX; (h) "New Product" means the XXXXXXXXXX product; (i) "non-resident" has the meaning assigned by subsection 248(1) of the Act; (j) "Parent" means XXXXXXXXXX; (k) "Province" means XXXXXXXXXX; (l) "Pubco" means XXXXXXXXXX; (m) "related persons" has the meaning assigned by subsection 251(2) of the Act; (n) "S Corporation" means a corporation that has elected to be taxed under Subchapter S of Chapter 1 of the Internal Revenue Code; (o) "State 1" means XXXXXXXXXX; (p) "State 2" means XXXXXXXXXX; (q) "subsidiary wholly-owned corporation" has the meaning assigned by subsection 248(1) of the Act; (r) "taxable Canadian corporation" has the meaning assigned by subsection 89(1) of the Act; (s) "Territory" means Canada; and (t) "Treaty" means the Convention between Canada and the United States of America with Respect to Taxes on Income and Capital signed on September 26, 1980 as Amended by Protocols signed on 14 June 1983, March 28, 1984, March 17, 1995, July 29, 1997 and September 21, 2007. ...